SuDS Consultation Round-Up

Written by: , 17 Dec 2014

SuDS on a housing estate

The strength of response to the Government’s consultation on Delivering Sustainable Drainage Systems has given politicians and policymakers much to consider before finalising the introduction of a new system in Spring 2015.

Reaction in the press and social media has been vocal, and industry and environmental groups have raised many concerns, whilst some have acknowledged that the joint Defra and DCLG proposals might offer a practical – and immediate – way forward.

Indications via the ‘Twittersphere’ suggest that Defra has received more than 400 submissions and that a response from the Government could be expected this month. The Tweet came from Daniel Johns Head of Adaptation for the UK Committee on Climate Change (CCC).

The CCC also has reservations about the proposals and Lord Krebs, Chair of the Adaptation Sub-Committee wrote to Environment Secretary Liz Truss to express his concerns:

“The revised approach relies on the planning system to encourage SuDS by creating an “expectation” that they will be used in new development. My Committee considers this to be a significant weakening of what was recommended by the Pitt Review in 2008 and subsequently endorsed by Parliament in the 2010 Flood and Water Management Act,” he writes, with particular worries about proposals to exclude minor development and to retain the automatic right to connect new development to sewers.

“Our concern is that the planning system alone, without resolving the issues Pitt identified, will not deliver the increase in the uptake of sustainable drainage systems desired,” he continues.

But some responses acknowledged the proposals were an attempt to address industry concerns, particularly amongst developers:  In his balanced analysis of the proposals “U-Turn for the SuDs Campaign Bus?” Daniel Hayes Director of Civil Engineering at consultants Peter Brett Associates writes:

“So industry concerns seem to have at last been heard. If the separate consenting regime is not introduced, SuDS will not be placed above all other material planning considerations, as developers had feared, and there will be no increase in development risk, cost and programme.”

The Home Builders’ Federation, whose members build about 80% of the new homes constructed each year, offered a cautious welcome. “The consultation takes us closer to how we believe the effective management and control of surfaces water should be dealt with in a consistent manner,” says a response on the HBF’s website, stating that the final policy “needs to be clear, concise, viable, and proportionate to deliver the consistency required.”

However, some responses were strongly opposed to the revised plans. Gareth Twohey, National Sector Manager for Utilities at builders merchants Keyline, warned that changing the course of the implementation of much-needed SuDS (Sustainable Urban Drainage Systems) from a legislation-based approach to piecemeal local planning could be fatal:

“By nature, local planning looks at local needs when it comes to new development, and not at the wider context. SuDS has to be holistic rather than site-specific to work properly, looking at the crucial ramifications downstream of new installations. Moving the problem onto someone else’s patch could result in a nightmare scenario, when more joined-up thinking might have mitigated this risk.”

Alex Stephenson, chair of the British Water Surface Water Management Focus Group and Group Market Development Director of Hydro International also warned that the proposals could pave the way for a ‘free-for-all’ that could jeopardise effective flood control. In particular, the revised implementation plans could fall short in protecting environmental water quality.

“Despite the Government’s intentions, the outcome could well be a fudge and a ‘post code’ lottery that sees fewer schemes built to SuDS principles with no robust way of ensuring they will be maintained or work as designed,” he said.

CIWEM, the Chartered Institution of Water and Environment Management also stated strong reservations: “The policy does little more than maintain the status quo… and the current arrangements have not proven to deliver sufficient SuDS because of uncertainty over who will adopt and maintain and the continuing ‘right to connect’ storm water to sewerage systems.”

The response of the Environmental Industries Commission, UK’s environmental technologies and services sector, was also widely reported:

“The Government’s new proposal to deliver SuDS through the planning system is the path of least resistance – it will see SuDS delivered quickly, but not automatically to a high standard.

“We have some concern over consistent high quality delivery across planning authorities. However, whilst this new approach is not ideal, it is workable – and believe it preferable to find a workable version of these latest proposals than starting again and incurring further delays.”

Fudge and Free-For-All? What to Make of The Alternative SuDS Plan? – See Alex Stephenson’s blog on the consultation.

Links to a selection of responses to the consultations are provided below.

Home Builders’ Federation

Committee on Climate Change

Peter Brett Associates

Environment Industries Commission



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